This compilation indexes twelve High Court rulings — decided between September 2025 and April 2026 — in which Section 73(10) of the Central Goods and Services Tax Act, 2017 (and its State GST mirror provisions) was directly engaged. The cases span the Gauhati, Bombay, Karnataka, and Madras High Courts and arise from writ petitions challenging show-cause notices, demand orders, and allied extension notifications. The compilation is intended as a starting-point reference for in-house tax teams, Big-4 associates, and law firm researchers tracking judicial treatment of the statutory time limits under Section 73.

Research index only. This article is a structured case-law reference. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Always verify against the full text of each judgment and consult qualified counsel before acting.

The statutory framework in one paragraph

Section 73 of the Central Goods and Services Tax Act, 2017 (and its identically structured State GST counterparts) governs the determination of tax not paid, short-paid, erroneously refunded, or input tax credit wrongly availed or utilised, in cases not involving fraud, wilful misstatement, or suppression of facts. Sub-section (10) prescribes the outer time limit within which the proper officer must issue the order of determination: the order must be passed within three years from the due date for furnishing the annual return for the financial year to which the tax not paid or short-paid or the input tax credit wrongly availed or utilised relates, or within three years from the date of erroneous refund. This limitation provision has generated substantial writ-court litigation concerning the validity of show-cause notices, demand orders, and government notifications that purport to extend the prescribed timeline.

The 12 rulings

1. Page No.# 1/5 vs The State Of Assam And 3 Ors

Bench: Gauhati High Court
Date: 6 April 2026
Sections engaged: 29, 73(10), 44
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as WP(C)/1446/2026 before the Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh), with the petitioner being R P Infratech and Anr, represented by its partner, challenging respondents including the State of Assam, the Commissioner of State Tax, the Assistant Commissioner of State Tax, and the Joint Commissioner of State Tax. Per the source preview, the full judgment was pronounced on 06.04.2026 and counsel for both sides were heard; the substantive grounds of the order are not reproduced in the available preview.

2. Saifee Hospital Trust vs The State Of Maharashtra

Bench: Bombay High Court
Date: 13 March 2026
Sections engaged: 168A, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (Writ Petition No. 4374 of 2025) was filed under Article 226 of the Constitution of India before the Bombay High Court seeking, among other reliefs, a writ of certiorari to quash Notification No. 56/2023-CT dated 28.12.2023 issued by respondent no. 4 and Notification No. 56/2023-State Tax dated 16.01.2024 issued by respondent no. 1, on the ground that the said notifications were illegal, unconstitutional, and ultra vires. The challenge also extended to consequential records; the operative outcome is not disclosed in the available source preview.

3. Rite Equipments P Ltd vs State Of Maharashtra

Bench: Bombay High Court
Date: 25 February 2026
Sections engaged: 168A, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 1443 of 2025, the petitioner challenged the Notification dated 28 December 2023 issued by the respondents exercising powers under Section 168A of the Central Goods and Service Tax Act, 2017. Counsel for the petitioner drew the Court's attention to a similar issue considered in Shyam Udyog vs. Union of India & Ors. (Writ Petition (L) No. 10058 of 2025), in which a co-ordinate bench passed an interim order dated 16 April 2025 granting liberty to parties to apply depending on the outcome before the Supreme Court; the final operative order in the present petition is not disclosed in the available source preview.

4. M/S M G Wadhwani, Through Proprietor vs Union Of India, Thr. Secretary

Bench: Bombay High Court
Date: 13 February 2026
Sections engaged: 74, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 3902/2025 before the Bombay High Court (Nagpur Bench), the petitioner challenged a show-cause notice dated 21/05/2024 issued under Section 74 of the CGST Act by the Joint Commissioner, Central Goods and Services Tax, Nagpur-I, pertaining to the period from July 2017 to January 2024, alleging suppression of taxable value and short payment of CGST. The petitioner's counsel argued that clubbing of multiple periods while issuing a notice under Section 74 is impermissible, relying on a Division Bench judgment at Goa in M/s. Milroc Good Earth Developers vs. Union of India & Ors. (Writ Petition No. 2203/2025 decided on 9/10/2025), wherein it was held that an authority lacking jurisdiction cannot issue a composite notice; the operative outcome of the present petition is not disclosed in the available source preview.

5. Icad School Of Learning Pvt. Ltd vs Union Of India, Thr. Secretary, Dept. Of

Bench: Bombay High Court
Date: 6 February 2026
Sections engaged: 74, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: Writ Petition No. 736 of 2026 was filed before the Bombay High Court (Nagpur Bench) by ICAD School of Learning Pvt. Ltd., Tilak Nagar, Nagpur, challenging a show-cause notice dated 01/05/2025 issued under Section 74 of the CGST Act by the Joint Director, DGGI, Nagpur Zonal Unit, and the consequent order. Per the source preview, the Court heard arguments, including those of counsel for respondent nos. 1 to 4, and identified an additional reason bearing on the validity of the notice; the full operative outcome is not reproduced in the available preview.

6. Rainbow Greeners, Thr. Proprietor vs State Of Maharashtra, Thr. Additional

Bench: Bombay High Court
Date: 30 January 2026
Sections engaged: 74, 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 7945/2025 before the Bombay High Court (Nagpur Bench), the petitioner challenged a show-cause notice dated 18/06/2025 issued under Section 74 of the CGST Act by the Deputy Commissioner, CGST, Nagpur, pertaining to Financial Years 2018-19 to 2022-23. Per the source preview, the Court considered prior judgments on the question of consolidation of financial years in a single notice, and the order notes that consolidation would collapse those years; the petition was disposed of with liberty and for reasons set out in the order, though the full operative outcome is not reproduced in the available preview.

7. A.M. Marketplaces Pvt. Ltd. Thr. Its vs The Union Of India, Thr. The Ministry Of

Bench: Bombay High Court
Date: 17 January 2026
Sections engaged: 73(2), 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a subsequent hearing date in Writ Petition No. 7941 of 2025 before the Bombay High Court (Nagpur Bench) filed by A. M. Marketplaces Pvt. Ltd., New Delhi. Per the source preview, counsel for the petitioner was not pressing for orders on prayer clauses (c) and (d) of the petition at this stage, and the Court noted that a prior order passed on 9-1-2025 had observed that an order has to be passed by the proper officer within a period of three years; the operative outcome of this hearing is not disclosed in the available source preview.

8. A.M. Marketplaces Pvt. Ltd. Thr. Its vs The Union Of India, Thr. The Ministry Of

Bench: Bombay High Court
Date: 9 January 2026
Sections engaged: 73(2), 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is an earlier hearing date in Writ Petition Nos. 7941 to 7943 of 2025 before the Bombay High Court (Nagpur Bench) filed by A. M. Marketplaces Pvt. Ltd., New Delhi. Per the source preview, the Registry had not recorded its satisfaction as regards service to respondents, and the Court directed the Registry to examine the affidavit of service filed by the petitioner's counsel and make categorical remarks; no substantive order on the merits is reproduced in the available preview.

9. City Enterprises vs The Deputy State Tax Officer

Bench: Madras High Court
Date: 8 January 2026
Sections engaged: 73(2), 73(9), 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In WP No. 462 of 2026 (with WMP Nos. 566 & 568 of 2026) before the Madras High Court, the petitioner — City Enterprises, represented by its proprietor Mr. Subbaiyan Parameswaran, Coimbatore — sought a writ of certiorarified mandamus to quash the impugned order passed in Reference No. ZD3308241666734 in GSTIN/ID: 33AJQPP4913N1ZN dated 20.08.2024, for F.Y. 2019-20, on the grounds that it was illegal, without jurisdiction, and in violation of principles of natural justice, and to direct the respondent to redo the assessment after affording a proper opportunity of hearing. The source preview discloses a tax demand table showing SGST and CGST amounts alongside interest figures; the full operative order is not reproduced in the available preview.

10. M/S Business Aircraft Management vs The State Of Karnataka

Bench: Karnataka High Court
Date: 24 October 2025
Sections engaged: 73(9), 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 24010 of 2025 (T-RES) before the Karnataka High Court at Bengaluru, the petitioner M/s Business Aircraft Management Services Pvt. Ltd., HSR Layout, Bengaluru, sought to quash the impugned order dated 13.03.2024 passed by the Assistant Commissioner of Commercial Taxes, LGSTO-17, DGSTO-04, determining and directing the petitioner to pay tax, interest, and associated amounts. The writ was filed under Articles 226 and 227 of the Constitution of India; the full operative outcome is not disclosed in the available source preview.

11. M/S Manish Enterprises vs Union Of India

Bench: Karnataka High Court
Date: 16 October 2025
Sections engaged: 73(1), 73(10)
Outcome: Outcome not specified in source
Procedural / substantive ground: In Writ Petition No. 26907 of 2024 (T-RES) before the Karnataka High Court at Bengaluru, the petitioner M/s Manish Enterprises, Kilari Road, Bengaluru, sought to quash an impugned order of respondent no. 4 (Commercial Tax Officer (Audit)-3.8, DGSTO-3) in No. CTO(Audit)3.8/T.NO/2024-25 dated 01.07.2024. The writ was filed under Articles 226 and 227 of the Constitution of India; the full substantive grounds and the operative outcome are not reproduced in the available source preview.

12. M/S. Kandan Traders vs The Assistant Commissioner

Bench: Madras High Court
Date: 16 September 2025
Sections engaged: 73(9), 73(10), 74(9)
Outcome: Outcome not specified in source
Procedural / substantive ground: In W.P. No. 34442 of 2025 (with W.M.P. Nos. 38590 & 38591 of 2025) before the Madras High Court, M/s. Kandan Traders, represented by its managing partner C. Kandan, Red Hills, Thiruvallur, Chennai, challenged Order-in-Original No. 342/2024-GST (AC) dated 30.08.2024, issued for the period 2020-2021, seeking its quashing as illegal and arbitrary. Per the source preview, when the matter was called — both in the morning and in the post-session — there was no representation for the petitioner; the matter was listed for admission and the operative outcome is not reproduced in the available preview.

Patterns across these 12 rulings

Notification-validity challenges under the limitation-extension provision. Two cases (cases 2 and 3) both directly challenge Notification No. 56/2023-CT dated 28.12.2023 and its State Tax counterpart dated 16.01.2024, which were issued purportedly under the power to extend time limits. This reflects a discernible pattern of taxpayers questioning whether such extension notifications are legally valid, particularly in the context of the outer time limit for passing orders.
Composite or multi-year notice challenges. At least three cases (cases 4, 5, and 6, all before the Bombay High Court, Nagpur Bench) involve challenges to show-cause notices that clubbed or consolidated multiple financial years or periods into a single notice. The recurring argument across these cases is that consolidation of periods in a single notice is impermissible, with the petitioners relying on earlier coordinate-bench authority.
Recurring party and multi-date hearings. Cases 7 and 8 involve the same petitioner (A. M. Marketplaces Pvt. Ltd.) and the same writ petition numbers (7941–7943 of 2025) at different hearing dates (9 January 2026 and 17 January 2026). This illustrates that a single writ petition may generate multiple indexed entries as the matter is heard across dates, and researchers should cross-reference hearing dates when reviewing the same case number.
Article 226 as the primary vehicle. All twelve cases reached the High Courts by way of writ petitions under Article 226 (and in some cases Article 227) of the Constitution of India, rather than through the statutory appellate route, suggesting that limitation and jurisdiction objections under Section 73(10) are frequently treated by taxpayers as amenable to direct writ challenge.
Absence of disclosed operative outcomes. Across all twelve entries in this compilation, the source preview does not disclose a final operative outcome in any case. Researchers should treat these entries as indicative of the nature of the challenge and the sections engaged, and must access the full judgment text to determine how each court ultimately disposed of the petition.

How to use this compilation

This compilation is organised by hearing date (most recent first) and indexes the key identity fields — bench, date, sections engaged, and outcome direction — drawn from the TaxNoticeAI structured legal corpus. To conduct effective research using these entries, begin by identifying the specific sub-section of Section 73 most relevant to your query (for example, the three-year order-passage limitation under sub-section (10), or the limitation for issuing a show-cause notice) and filter the table accordingly. Where multiple cases share the same writ petition number across different hearing dates, read all entries together to reconstruct the procedural history of that matter.

Before placing any reliance on these entries for internal analysis or filing purposes, verify the full text of each judgment through the official court portal, indiankanoon.org, or a recognised legal database. Check whether the judgment has been stayed, appealed, or reversed by a higher court. Several of the cases in this compilation were at an interlocutory or admission stage as of the indexed date, and the source preview does not confirm a final disposal; the position of law in any given case can only be confirmed from the complete judgment.

Additionally, researchers should check whether any relevant CBIC circular, instruction, or notification has been issued after the date of the judgment that may affect its applicability. Where a case turns on the validity of a specific government notification (such as the extension notifications cited in cases 2 and 3), verify the current status of that notification and any Supreme Court proceedings concerning it before drawing conclusions about the broader legal position.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 73(10) GST: 12 High Court Rulings on Limitation and Show-Cause Notices (2025–2026)